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Home My WebLink AboutAQ_F_1900039_20190813_CMPL_Fac-Ltr SOUTHERN VENEER r. , SPECIALTYPRODUCTS o I~ N O o M August 9, 2019 w = � o .4 North Carolina Department of Environmental Quality A Division of Air Quality v Raleigh Regional Office z p v�.. �S-I2-I�� 3800 Barrett Drive, Suite 101 Raleigh, NC 27609 SUBJECT: Notice of Violation Response -Title V Monitoring and Recordkeeping Requirements General Condition 3.B Requirements Southern Veneer Specialty Products, LLC - Moncure Moncure, Chatham County, North Carolina Air Permit No. 03424T28 Facility ID No. 1900039 To Whom It May Concern, This letter is in response to the North Carolina Division of Air Quality (DAQ) compliance inspection of Southern Veneer Specialty Products, LLC - Moncure, dated June 24, 2019, conducted by Matthew Mahler. During the inspection, Mr. Mahler discovered several violations of the Title V permit monitoring, recordkeeping, and permit availability requirements detailed in your facility's current Air Permit No. 03424T28 Southern Veneer Specialty Products, LLC acquired the Moncure facility from Boise Cascade in February 2019. The personnel previously responsible for preparation of the monitoring data and compliance reports is no longer at the Moncure facility. The violations discovered are described and answered below. 1. The facility did not retain and have available a copy of the current air permit. On page 23 of your air permit, General Condition 3,8 Permit Availability requires that the facility shall have available at the facility a copy of this permit. At the time of the audit, the air permit was stored in the safety office and not with the inspection documents. A new air permit was issued to the EHS Coordinator by Matthew Mahler. As a corrective action, the EHS Coordinator will be organizing all permitting and compliance records into an Environmental filing system that will be available for inspection upon request. 306 Corinth Rd Moncure,NC 27559 NCDEQ DAQ Response to NOV August 9,2019 Page 2 of 2 2. A review of the facility's permit recordkeeping revealed that the facility was not recording and maintaining records of the monthly amounts of wood fuel fired in the boiler from March 2019 through May 2019. Personnel responsible for maintaining all environmental records, including wood fuel fired in the boiler, left the company abruptly during the acquisition. As a result, the environmental requirements were not communicated to the current personnel. To prevent the gap in communication from reoccurring, the EHS Coordinator and a designated backup person will be responsible for recording and maintaining records specific to the monthly amounts of wood fuel fired in the boiler. After the compliance inspection, the EHS Coordinator was able to determine that proprietary datalogging software previously used to record operating parameters was deactivated during the ownership transition. The company is working to recover the missing data from March through May 2019, that was previously being captured by the software. While the systems are being restored, the monthly amounts of wood fuel fired in the boiler will be calculated manually by operations staff. A third-party consultant will be on-site in the coming weeks to assist Southern Veneer Specialty Products, LLC in improving existing procedures and data management processes to help address any remaining compliance gaps. 3. On April 30, 2019 and May 6, 2019, the facility did not monitor or record the differential pressure drop across the multicyclone which controlled the fluidized bed wood burner. To ensure that no further inspections are missed, the EHS Coordinator and a Production Supervisor will review the multicyclone logs on a daily basis. For any deviations that occur, corrective action logs have been implemented and staff has been training to document a description of the event, cause, and actions taken to correct the deviation and minimize emissions during the event. 4. The facility's permit record keeping revealed that the facility was not monitoring and recording the monthly hazardous air pollutants (HAPs) emissions from March 2019 through May 2019. Personnel responsible for maintaining records of HAPs emissions left the company abruptly during the acquisition. As a result, the environmental requirements were not communicated to the current personnel. To prevent the gap in communication from reoccurring, the EHS Coordinator and a designated backup person will be responsible for maintaining the records necessary to prepare the HAP emissions calculation and reviewing the records weekly to ensure that no data gaps exist. After the compliance inspection, the EHS Coordinator was able to determine that proprietary datalogging software previously used to record operating parameters was deactivated during the ownership transition. The company is working to recover the missing data from March through May 2019, that was previously captured by the software. While the systems are being restored, other procedures are being put in place to capture the operating data needed to complete the calculations. A third-party consultant will be on-site in the coming weeks to assist Southern Veneer Specialty Products, LLC in improving existing procedures and data management processes to help address any remaining compliance gaps. 306 Corinth Rd. Moncure.NC 27559 NCDEQ DAQ/Response to NOV August 9,2019 Page 2 of 2 If there are any questions or if more information is required, please call Thomas Reams, EHS Coordinator at 910-605-9258_ Sincerely, vy�� Rick Payne Plant Manager Southern Veneer Specialty Products, LLC 306 Corinth Rd. Moncure,NC 27559